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To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a Tax Services Office or Taxation Centre of Canada Revenue Agency ("CRA") in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayers or a related person; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

In our view, however, a qualifying period is only considered to commence on the first day an employee performs his duties of employment outside Canada. ...

To the best of your knowledge and that of Parent, none of the proposed transactions involved in this ruling letter: (i) is in an earlier return of Parent or any persons related to Parent, (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of Parent or any persons related to Parent, (iii) is under objection by Parent or any persons related to Parent, or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

Position: The right to cut Christmas trees, which is for a limited period, is considered Class 14 property. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request herein is: (i) in a return of the Trust, ACo or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Trust, ACo or a related person; (iii) under objection by the Trust, ACo or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA to the Trust or ACo, or a related person, XXXXXXXXXX; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

The property would not have an acquisition cost for the purchaser and the consideration for that part of the deal would be considered CEE if the expenses otherwise qualify. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a Tax Services Office or Taxation Centre of Canada Revenue Agency ("CRA") in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayers or a related person; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Further, providing a key service traditionally offered by the provinces or territories such as social services, overseeing of the environment, health services, or education is generally considered to constitute performing a function of government. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Lossco, Profitco, or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Lossco, Profitco, or a related person; (iii) under objection by Lossco, Profitco, or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Lossco, Profitco, or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

An adjustment to Schedule 1 of the corporation return of income will need to be considered in order to reconcile the net income of the corporation per the financial statements with the net income for income tax purposes for the fiscal period during which the change takes place. ...